Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
An order granting valuation and the first opportunity to purchase shares was treated as self-operative: once the fair value reports were available, the appellant had to accept the valuation and indicate willingness to buy, without any further formal offer. By rejecting the higher valuation and seeking averaging of the reports, the appellant failed to exercise the first option, so the respondents' right to purchase the shares at the accepted fair value crystallised. The Tribunal also held that a later challenge to the valuation and a belated offer to buy could not revive a waived right after the arrangement had been acted upon. The appeal was dismissed and the sale in favour of the respondents was sustained.
An order granting valuation and the first opportunity to purchase shares was treated as self-operative: once the fair value reports were available, the appellant had to accept the valuation and indicate willingness to buy, without any further formal offer. By rejecting the higher valuation and seeking averaging of the reports, the appellant failed to exercise the first option, so the respondents' right to purchase the shares at the accepted fair value crystallised. The Tribunal also held that a later challenge to the valuation and a belated offer to buy could not revive a waived right after the arrangement had been acted upon. The appeal was dismissed and the sale in favour of the respondents was sustained.
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